Effective Date: 25th May, 2026  |  Last Updated: 25th May, 2026  |  Version: 2.0

These Terms apply to all users of HorizonPay's services — including agents, merchants, end-use customers, and website visitors — and must be read together with our Privacy Policy, which forms an integral part of this agreement.

1. Definitions and Interpretation

In these Terms and Conditions, unless the context otherwise requires, the following terms shall have the meanings ascribed to them below:

Term	Meaning
"HorizonPay"	HorizonPay Nigeria Limited, a company duly incorporated in Nigeria and licensed as a Super Agent by the Central Bank of Nigeria, with its registered office at 74, Oduduwa Crescent, GRA, Ikeja, Lagos, Nigeria.
"Agent"	Any individual or business entity onboarded by HorizonPay to provide agency banking services on behalf of a Principal (licensed financial institution) through HorizonPay's Super Agent network.
"Merchant"	Any individual or business entity that uses HorizonPay's payment solutions strictly for the purpose of accepting payments from customers via approved channels.
"Customer" / "User"	Any individual or entity who accesses or uses HorizonPay's services, website, POS devices, or applications.
"Principal"	The CBN-licensed financial institution (bank or other entity) on whose behalf Agent Banking services are rendered through HorizonPay's network.
"POS Device"	Any Point-of-Sale terminal provisioned by or through HorizonPay, including the HorizonPay T50 Mobile POS, HorizonPay K11, and HorizonPay K11 Lite.
"Services"	All products and services offered by HorizonPay, including agency banking (9rapoint platform), merchant payment services, Smartlink debit-card routing, White Labelling solutions, POS device provisioning, fund transfers, bill payments, airtime top-up, subscriptions, balance enquiries, loan disbursements and repayments, and voucher services.
"CBN"	Central Bank of Nigeria.
"NDPA"	Nigeria Data Protection Act, 2023.
"NDPC"	Nigeria Data Protection Commission.
"NIBSS"	Nigeria Inter-Bank Settlement System Plc.
"NFIU"	Nigerian Financial Intelligence Unit.
"AML/CFT"	Anti-Money Laundering and Combating the Financing of Terrorism.
"KYC/CDD"	Know Your Customer / Customer Due Diligence, as prescribed by the CBN.
"STR/CTR"	Suspicious Transaction Report / Currency Transaction Report, as required by the NFIU Act.

2. Acceptance of Terms

By accessing our website at www.horizonpay.ng, registering as an agent or merchant, using any of our POS devices, or utilising any of our services, you acknowledge that you have read, understood, and agree to be bound by these Terms and Conditions, our Privacy Policy, and any other applicable policies, agreements, or regulatory requirements.

We reserve the right to amend these Terms at any time. Changes will become effective upon posting on our website. Material changes will be communicated via website notice and, where practicable, directly to registered users. Your continued use of our services after such posting constitutes your acceptance of the revised Terms.

3. Eligibility

To access and use our services, you must satisfy all of the following conditions:

• Be at least 18 years of age and possess the full legal capacity to enter into binding contracts under Nigerian law.
• Provide accurate, complete, and current identification and verification documents, including a valid BVN, NIN, and government-issued ID document, as required by CBN KYC regulations and the tiered-KYC framework.
• For Agents: Operate a registered business (or demonstrate verifiable trade activity), pass all due diligence checks including BVN/NIN verification and background screening, and execute a formal Agent Banking Agreement with HorizonPay.
• For Merchants: Provide valid business registration documents (CAC certificate) and comply with all merchant onboarding, KYC, and compliance requirements.
• Not be listed on any sanctions or watchlists maintained by the CBN, NFIU, EFCC, OFAC, United Nations Security Council, European Union, or other relevant domestic or international bodies.
• Not have been previously suspended or terminated by HorizonPay or another CBN-licensed Super Agent for breach of terms, regulatory infractions, or financial crime.

4. Services Provided

HorizonPay provides the following services through its CBN-licensed Super Agent network:

4.1 Agency Banking — 9rapoint Platform

Through our 9rapoint platform, agents provide the following services on behalf of licensed Principal financial institutions:

• Cash deposits and withdrawals (cash-in / cash-out)
• Interbank and intra-bank fund transfers
• Bill payments and subscription services
• Airtime and data top-up
• Account balance enquiries
• Loan disbursements and repayment collections
• Voucher and prepaid card services
• Purchase transactions

4.2 Merchant Services

Merchants use our platform and POS devices strictly for the acceptance of payments from customers through approved channels.

4.3 Smartlink Service

Smartlink is HorizonPay's proprietary debit-card routing service, enabling platform owners and developers to integrate card-based payment processing into Android applications, with transactions routed to NIBSS or other CBN-approved payment switches.

4.4 White Labelling Solutions

HorizonPay offers white-label agency banking technology solutions for businesses seeking to deploy their own branded payment services, leveraging our licensed platform and device manufacturing capacity.

4.5 POS Device Provisioning and Management

HorizonPay supplies, configures, geo-fences, and manages POS devices including the HorizonPay T50 Mobile POS, HorizonPay K11, and HorizonPay K11 Lite, in accordance with CBN specifications.

5. Agent and Merchant Obligations

By registering as an Agent or Merchant with HorizonPay, you accept all of the following obligations as conditions of your continued engagement:

5.1 General Obligations

• Comply fully and at all times with applicable Nigerian laws, CBN Agent Banking Guidelines, AML/CFT regulations, KYC/CDD requirements, the NDPA 2023, and all HorizonPay policies.
• Maintain accurate, complete, and up-to-date records of all transactions processed through our platforms.
• Display all CBN-mandated signage, identification materials, service menus, and complaint procedure notices prominently at your approved business location(s).
• Operate exclusively from the approved and geo-fenced registered business location(s).
• Not engage in any activity that is fraudulent, deceptive, misleading, or in contravention of applicable Nigerian law.
• Report any suspicious transactions, fraud incidents, or security concerns to HorizonPay and the relevant authorities (NFIU, EFCC) immediately upon discovery.
• Maintain adequate liquidity (float) at all times to meet customer transaction demands at your location.

5.2 CBN Exclusivity and Single-Principal Rule

5.3 Confidentiality and Data Protection

• Maintain strict confidentiality of all customer data, transaction information, and HorizonPay's proprietary business information at all times.
• Not use customer data for any purpose other than the provision of the authorised Services under these Terms.
• Comply with the HorizonPay Privacy Policy and all obligations under the NDPA 2023 and NDPR 2019.
• Promptly notify HorizonPay of any actual or suspected data breach or unauthorised disclosure of customer information.
• Any breach of confidentiality or data protection obligations may result in immediate termination of your engagement, financial liability, and referral to the NDPC and/or NFIU.

5.4 KYC and AML/CFT Compliance

• Verify the identity of all customers in accordance with the CBN's tiered-KYC framework (Tier 1, Tier 2, and Tier 3) before processing any transaction.
• Not process transactions that exceed the daily, single-transaction, or cumulative limits prescribed by the CBN for the relevant KYC tier, or as otherwise directed by HorizonPay.
• File STRs and CTRs as required under the Money Laundering (Prohibition) Act 2022, Terrorism (Prevention and Prohibition) Act 2022, and applicable NFIU guidelines.
• Not structure, split, or arrange transactions in any manner intended to circumvent prescribed transaction limits or reporting obligations (smurfing).
• Complete all mandatory AML/CFT, data protection, and consumer protection training programmes provided by HorizonPay or its designated trainers.

5.5 POS Device Usage and Responsibility

• POS devices remain the property of HorizonPay (or the relevant Principal) at all times and must be returned in good working condition upon termination of your engagement.
• You must not tamper with, modify, reverse-engineer, clone, or attempt to circumvent the hardware or software security features of any POS device.
• All POS devices are geo-fenced to your registered and approved business location. Operating any POS device outside the approved geo-fence is a direct violation of CBN Agent Banking Guidelines and these Terms.
• You are solely responsible for the physical security, safe custody, and proper use of all POS devices in your possession.
• Any damage, loss, theft, or unauthorised use of a POS device must be reported to HorizonPay in writing within 24 hours of discovery. Failure to report promptly may result in financial liability for the device replacement cost and any resultant losses.
• You must not allow any unauthorised person to use, access, or handle any POS device assigned to you.

6. Customer Obligations

As a customer using HorizonPay's services (including transactions conducted at agent and merchant locations), you agree to the following:

• Provide accurate, truthful, and current identification information as required by the applicable KYC tier for the transaction being conducted.
• Not use our services for any unlawful purpose, including but not limited to money laundering, terrorist financing, fraud, identity theft, or any other financial crime under Nigerian law.
• Carefully verify all transaction details — including the amount, recipient/beneficiary information, and transaction type — before authorising any transaction. Transactions once authorised and processed may be irreversible.
• Retain all transaction receipts as proof of your transactions.
• Report any unauthorised transactions, suspected fraud, or discrepancies to HorizonPay immediately through our complaint channels.
• Not share your account credentials, PINs, passwords, or one-time passwords (OTPs) with any third party.

7. Transaction Limits

All transactions are subject to limits prescribed by the CBN, the relevant Principal, and HorizonPay's risk management framework. These limits are aligned with the CBN's tiered-KYC account structure:

• Tier 1 (Basic KYC): Minimum requirements — name, phone number, and BVN. Subject to CBN-prescribed limits for low-value agency banking transactions.
• Tier 2 (Medium KYC): Tier 1 requirements plus NIN, address verification, and additional documentation. Subject to higher CBN-approved transaction limits.
• Tier 3 (Full KYC): Complete identity verification including government-issued photo ID, proof of address, and enhanced due diligence. Eligible for the highest transaction limits as approved by the Principal and CBN.

In addition to the above:

• HorizonPay reserves the right to impose additional or more restrictive limits for risk management or compliance purposes, at its sole discretion.
• Transaction limits may be revised from time to time in accordance with CBN directives and circulars, without prior notice to agents or customers where required by regulation.
• Agents must not process any single transaction or series of transactions that would cause them to exceed their prescribed daily or cumulative limits.

8. Fees and Charges

• Fees and charges applicable to our services are as agreed in the relevant Agent Banking Agreement or Merchant Agreement, or as published on our website and platforms from time to time.
• HorizonPay reserves the right to revise fees and charges. You will be notified of any changes in advance, in accordance with the CBN Consumer Protection Framework.
• All applicable taxes, including Value Added Tax (VAT) and withholding tax, shall be borne by the relevant party as required under the Finance Act and applicable Nigerian tax laws.
• Agent commissions are settled through the agreed settlement process and within the timelines specified in the Agent Banking Agreement.
• Agents are strictly prohibited from charging customers any fees, levies, or commissions beyond the approved and published schedule. Unauthorised surcharging constitutes a breach of the CBN Consumer Protection Framework and these Terms and may result in immediate termination.

9. Settlement and Reconciliation

• All transaction settlements will be processed through the dedicated CBN-monitored settlement account or wallet as mandated by the CBN Agent Banking Guidelines.
• Settlement timelines are as specified in your Agent or Merchant Agreement and are subject to the operational clearing cycles of the Principal and NIBSS.
• You are responsible for performing daily transaction reconciliation and must promptly report any discrepancies, shortfalls, or errors to HorizonPay within the prescribed reconciliation window.
• Disputed transactions must be formally escalated within 72 hours of the transaction date using the prescribed dispute resolution channel.
• HorizonPay shall not be liable for delays in settlement arising from acts or omissions of the Principal, NIBSS, telecommunications providers, or events of force majeure.

10. Intellectual Property

• All intellectual property rights in the HorizonPay brand, logo, trade name, website, 9rapoint platform, Smartlink service, proprietary software, mobile applications, and all related materials are owned exclusively by HorizonPay or its licensors and are protected under applicable Nigerian intellectual property laws.
• You are granted a limited, non-exclusive, non-transferable, revocable licence to use our platforms and services solely for the purposes expressly authorised under these Terms and your applicable agreement.
• You must not copy, reproduce, reverse-engineer, modify, distribute, sublicense, or create derivative works based on any HorizonPay intellectual property without our prior express written consent.
• Agents and Merchants must use HorizonPay branding and marketing materials only as authorised in writing and strictly in accordance with our Brand Guidelines.

11. Data Collection, Privacy, and Regulatory Compliance

Your use of our services is governed by our Privacy Policy, which forms an integral part of these Terms and Conditions. By using our services, you acknowledge and consent to the collection, processing, retention, and use of your personal data as described in our Privacy Policy, in compliance with the following regulatory frameworks:

• Nigeria Data Protection Act (NDPA) 2023: We process personal data in accordance with the seven lawful processing principles: lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality; and accountability. We have appointed a Data Protection Officer (DPO) and submit annual DPCA returns to the NDPC through a licensed DPCO.
• CBN Agent Banking Guidelines: We collect, encrypt, and retain transaction, identity, and KYC data as mandated by the CBN, including mandatory minimum five-year retention, transaction traceability, and geo-location data for POS devices.
• NDPC Technical Standards and Guidelines: All data processing systems comply with NDPC technical standards including encryption, access controls, VAPT requirements, and incident response protocols.
• CBN Risk-Based Cybersecurity Framework: We implement the CBN's prescribed cybersecurity controls for financial institutions, including the protection of customer financial data and payment infrastructure.
• AML/CFT Laws: We collect and process identity and transaction data to comply with the Money Laundering (Prohibition) Act 2022, the Terrorism (Prevention and Prohibition) Act 2022, and all applicable NFIU directives, including mandatory STR and CTR filing obligations.

12. Consumer Protection

In accordance with the CBN Consumer Protection Framework (CPF) 2016 and all subsequent CBN consumer protection directives, the following rights and protections apply to all customers of HorizonPay's services:

• Agents must prominently display, at their approved business location, a clear notice of all available services, applicable fees, and customer complaint procedures, as mandated by the CBN.
• Customers are entitled to a printed or electronic transaction receipt for every completed transaction. Agents must not refuse to issue receipts.
• Customers have the right to lodge complaints regarding any aspect of our services without fear of retaliation or discriminatory treatment.
• No service may be refused on grounds of ethnicity, religion, gender, disability, or any other protected characteristic under applicable Nigerian law.
• Customers who are dissatisfied with the outcome of their complaint at the agent level may escalate to HorizonPay directly.

13. Prohibited Activities

The following activities are strictly prohibited when using HorizonPay's services. Engaging in any of these activities may result in immediate suspension or termination, reporting to regulatory authorities, and civil or criminal prosecution under applicable Nigerian law:

• Engaging in or facilitating money laundering, terrorist financing, proliferation financing, or any other financial crime under the Money Laundering (Prohibition) Act 2022, Terrorism (Prevention and Prohibition) Act 2022, or any other applicable law.
• Processing fraudulent, fictitious, fictitiously split (structured/smurfed), or unauthorised transactions.
• Operating a POS device outside your approved and geo-fenced business location, or exceeding prescribed KYC-tier transaction limits.
• Accessing or attempting to access systems, accounts, or data belonging to other users or HorizonPay without authorisation.
• Introducing or attempting to introduce viruses, malware, ransomware, spyware, or any other harmful or disruptive code into HorizonPay's systems or networks.
• Circumventing, disabling, tampering with, or interfering with any security, geo-fencing, or authentication features of our platforms or POS devices.
• Using our services in any manner that violates applicable Nigerian laws, CBN regulations, NFIU directives, or these Terms.
• Charging customers any fees, surcharges, or commissions not expressly authorised in the published fee schedule.
• Sharing, transferring, sublicensing, or assigning your agent or merchant credentials, POS devices, or platform access to any unauthorised third party.
• Providing false, misleading, or fraudulent information during onboarding, KYC verification, complaint filing, or any regulatory or operational process.
• Conducting transactions for, or on behalf of, any person or entity on a sanctions or watchlist without the appropriate regulatory approval.

14. Suspension and Termination

14.1 Grounds for Suspension

HorizonPay reserves the right to immediately suspend your access to our services, with or without prior notice, where any of the following grounds exist:

• A suspected or confirmed breach of these Terms or any applicable regulatory requirement.
• Suspicious, anomalous, or potentially fraudulent activity detected on your account, platform access, or POS device.
• A regulatory directive, order, or instruction from the CBN, NFIU, EFCC, NDPC, or any other competent authority.
• Failure to comply with KYC, AML/CFT, data protection, or consumer protection obligations.
• Your POS device is detected operating outside the approved geo-fenced location.
• Failure to maintain adequate float levels or to perform timely reconciliation.

14.2 Termination

• Termination by Notice: Either party may terminate the business relationship by providing 30 days' written notice to the other party, subject to the terms of the applicable Agent or Merchant Agreement.
• Immediate Termination by HorizonPay: HorizonPay may terminate your engagement with immediate effect and without notice where you are found to have engaged in fraud, money laundering, terrorist financing, or any criminal activity; you materially breach these Terms and fail to remedy the breach within 14 days of written notice; termination is required by law, regulation, or regulatory directive; or your business licence, CAC registration, or any required regulatory approval is revoked, suspended, or lapses.

14.3 Effects of Termination

• Upon termination, you must immediately cease using all HorizonPay services, platforms, branding materials, and credentials.
• All POS devices must be returned to HorizonPay in good working condition within 7 business days of termination. Failure to return devices may result in deduction of the replacement cost from any outstanding commissions or legal action to recover the devices.
• Outstanding commissions and settlements will be processed in accordance with the applicable Agreement, net of any amounts owed to HorizonPay, within the normal settlement cycle.
• The following obligations survive termination of these Terms: confidentiality (Section 5.3), data protection, intellectual property, indemnification (Section 16), dispute resolution (Section 18), and governing law (Section 19).

15. Limitation of Liability

• HorizonPay's total aggregate liability to you for any claim or series of related claims arising under or in connection with these Terms shall not exceed the total fees or commissions paid to or by you in the 12 months immediately preceding the event giving rise to the claim.
• HorizonPay shall not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, including loss of profits, revenue, business opportunity, data, goodwill, or reputation, whether or not HorizonPay has been advised of the possibility of such damages.
• HorizonPay shall not be liable for any loss or damage arising from: your failure to comply with these Terms, KYC/AML/CFT obligations, or applicable law; unauthorised access to your account, credentials, or POS device caused by your failure to maintain adequate security; service interruptions, delays, or failures caused by the Principal, NIBSS, telecommunications providers, power failures, or force majeure events; errors or inaccuracies in transaction details provided by you or by the customer.

16. Indemnification

You agree to fully indemnify, defend, and hold harmless HorizonPay, its directors, officers, employees, agents, affiliates, and successors from and against all claims, proceedings, losses, liabilities, damages, fines, penalties, costs, and expenses (including reasonable legal and professional fees) arising from or related to:

• Your breach of these Terms or any applicable Nigerian law, regulation, or regulatory directive.
• Your negligence, fraud, wilful misconduct, or misrepresentation.
• Any third-party claim arising from your use — or misuse — of our services.
• Your failure to comply with KYC/CDD, AML/CFT, data protection, consumer protection, or geo-fencing obligations.
• Any regulatory fine, sanction, or penalty imposed on HorizonPay as a direct result of your non-compliance.

17. Force Majeure

HorizonPay shall not be liable for any failure or delay in performing its obligations under these Terms to the extent that such failure or delay is directly caused by events beyond its reasonable control, including but not limited to: acts of God, natural disasters, epidemics, pandemics, war, civil unrest, terrorism, riots, acts or directives of the Nigerian government, CBN, or other regulatory authorities, national grid power failures, telecommunications network outages, NIBSS infrastructure failures, industrial action, or any other extraordinary event.

HorizonPay will notify you of such circumstances as soon as reasonably practicable and will use all commercially reasonable efforts to mitigate the impact on service delivery.

18. Dispute Resolution

18.1 Internal Resolution

In the first instance, all disputes should be raised with HorizonPay through our complaint channels (see Section 12). We will acknowledge within 24 hours and aim to resolve within 14 business days.

18.2 Formal Dispute Resolution Process

Where a dispute is not resolved through internal channels, the parties shall follow the process below:

1. Negotiation: The parties shall attempt to resolve the dispute through good-faith negotiation within 30 days of written notice of the dispute.
2. Mediation: If negotiation fails, either party may refer the matter to mediation under the rules of the Lagos Court of Arbitration or the Lagos State Multi-Door Courthouse.
3. Arbitration: If mediation does not resolve the dispute within 30 days, either party may refer the matter to final and binding arbitration under the Arbitration and Mediation Act of Nigeria (2023). The seat of arbitration shall be Lagos, Nigeria; the language shall be English.

18.3 Regulatory Complaints

Nothing in this clause prevents either party from seeking relief from or lodging complaints with the CBN, NDPC, NFIU, EFCC, or any other competent regulatory authority at any time.

19. Governing Law and Jurisdiction

These Terms and Conditions shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, including but not limited to:

• CBN Act (as amended)
• Banks and Other Financial Institutions Act (BOFIA) 2020
• Nigeria Data Protection Act (NDPA) 2023
• Money Laundering (Prohibition) Act 2022
• Terrorism (Prevention and Prohibition) Act 2022
• NFIU Act
• CBN Consumer Protection Framework (CPF) 2016
• All applicable CBN guidelines, circulars, and directives

The courts of Lagos State shall have non-exclusive jurisdiction over any dispute not resolved by arbitration under Section 18.

20. Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction or regulatory authority, the remaining provisions shall continue in full force and effect. The offending provision shall be modified to the minimum extent necessary to render it valid, legal, and enforceable, while preserving the original commercial intent of the parties as far as possible.

21. Entire Agreement

These Terms and Conditions, together with our Privacy Policy and any applicable Agent Banking Agreement, Merchant Agreement, or Service Level Agreement (SLA), constitute the entire and complete agreement between you and HorizonPay regarding the subject matter herein. They supersede all prior negotiations, representations, warranties, understandings, and agreements, whether written or oral.

22. Waiver

No failure or delay by HorizonPay in exercising any right, power, remedy, or discretion under these Terms shall operate as a waiver thereof, nor shall any single or partial exercise preclude any other or further exercise of that right, power, or remedy. A waiver is only effective if given in writing and signed by an authorised representative of HorizonPay.

23. Assignment

You may not assign, transfer, subcontract, or delegate your rights, obligations, or liabilities under these Terms to any third party without the prior written consent of HorizonPay. HorizonPay may assign or transfer its rights and obligations under these Terms to any affiliate, successor entity, or acquirer of all or substantially all of its assets or business, with notice to you where practicable.

24. Notices

All formal notices required or permitted under these Terms shall be in writing and shall be deemed validly delivered when: delivered personally to the recipient; sent by registered post or courier to the recipient's registered address; or sent by email to the email address on record, with confirmation of delivery requested.

25. Updates to These Terms

HorizonPay reserves the right to update or modify these Terms and Conditions at any time to reflect changes in our operations, applicable laws, or regulatory requirements. Material changes will be posted on our website and, where practicable, communicated directly to registered users before taking effect. The "Last Updated" date at the top of this document reflects the most recent revision. Your continued use of our services after any changes constitutes your acceptance of the updated Terms.

26. Contact Us

For any questions, concerns, or feedback regarding these Terms and Conditions, please contact us:

Disclaimer: These Terms and Conditions are provided for operational and informational purposes. HorizonPay recommends that all Agents, Merchants, and Users seek independent legal advice regarding their specific obligations and rights under these Terms and applicable Nigerian law. These Terms are at all times subject to the overriding provisions of applicable Nigerian statute and CBN regulation. In the event of any conflict between these Terms and applicable law or CBN directive, the law and directive shall prevail.